Lidsing Garden Community SPD

Comment

Representation ID: 428

Received: 12/12/2025

Respondent: CPRE Kent

Landscape-led/North Downs National Landscape
We note the assertion that the proposed development will be landscape led. We would like to see this wording strengthened in terms of the landscape and its features being prioritised, with development working around it, rather than open space being incorporated after the development layout has been fixed. Landscape should come first.
In this vein, the SPD acknowledges that the allocation lies immediately within (new M2 junction) and adjacent to the Kent Downs National Landscape. However, the SPD currently relies on a generic “landscape-led” narrative without addressing the statutory duty under Section 85 of the Countryside and Rights of Way Act 2000, which requires all public bodies to further the purposes of National Landscapes.
As drafted, the SPD does not explain how this legal duty should shape development parameters, design responses, or detailed master planning. Given the proximity to one of Kent’s most sensitive protected landscapes, the SPD must go beyond indicating buffers or planting strategies and instead require explicit evidence - through Design Codes, LVIA-led parcel design, building height controls and settlement-edge strategies, demonstrating how each phase will contribute positively to conserving and enhancing the National Landscape.
Structural landscaping mitigation, particularly in the context of the designated National Landscape and its setting – including in relation to the new (elevated) junction works on the M2 – should be carried out at the preliminary stage, instead of during the identified 1-5 year window (590 dwellings) after commencement.

Comment noted.
The Framework Plans set out at Chapter 5 of the SPD capture the key structuring elements and principles, whilst also allowing for appropriate flexibility for further design work to consider matters in more detail and bring forward appropriate proposals.
Future planning applications will set out more details around the proposed layout of buildings, uses and infrastructure across the site. All future applications will be the subject of consultation and future decision making.
The SPD sets out guidance and principles across a number of key themes and topics, especially within 'Section C: Placemaking & Design Guidelines'. Each theme has a clear section which sets out 'Key Principles/Guidance' specific to each theme.
Future planning applications will have to consider and demonstrate how they have addressed all stated requirements.
The requirement for a landscape buffer along the M2 is included in the guidelines and principles for Landscape at Chapter 6.4. Officers agree that the need for a buffer along the M2 should also be made clear on Figure 23: Green & Blue Infrastructure Framework.
Officers agree that an additional principle should be added to Chapter 6.4 (Landscape) to more clearly relate to criterion (H)(V), (VI) and (VII) of Policy LPRSP4(B)

Comment

Representation ID: 429

Received: 12/12/2025

Respondent: CPRE Kent

Sustainability/bus services/local facilities
In relation to the provision of accessible facilities, sustainable transport and bus services, it should be made clear to developers that the allocation of land at Lidsing is absolutely dependent on the requirement that regular and reliable public transport be provided in order that the use of private car won’t be a pre-requisite for undertaking day to day tasks.

Green bridge
Provision of a green bridge over the M2, linking to the Capstone Valley Country Park and Darland Banks to the north is welcomed. However, to be effective is should specifically be set aside for the single purpose of wildlife.
Reference is made at paragraph 6.5.7 to the Natural England definition of a green bridge, but no guidance is given by the Council in terms of its expectations with regard to whether people will be able to use the bridge for cycling/walking or whether it will also be available for use by vehicular traffic.
It will be this public transport provision that makes the development sustainable. Without this key element, this community will be just another car-driven housing estate that bears no resemblance to the intentions behind a garden community.
While we welcome in principle the commitment to high frequency (half-hourly) buses with high quality bus shelters and infrastructure, there is no detail as to expected hours of operation. How will the local community be assured that this development meets the goal of being a sustainable without a commitment to a round-the-clock bus service? These services will need to be put in place as soon as the first dwellings are completed, in order to establish activity patterns that are not reliant on the private car.
It is noted that there is no reference to the provision of bus services to support transition away from using the private car. Phase 1 (from 2028) mentions bus diversions. It is assumed this relates to the diversion of existing off-site routes. Affirmative language needs to be used in relation to bus service provision.
In addition, it’s not clear from the phasing schedule when the local centre will be provided. As with public transport provision, car habits will already be established (and be difficult to break/change) if provision of on-site facilities are delayed. Consideration should be given to the provision of temporary structures, keeping pace with development, to create an immediate sense of community and belonging. Waiting until Phase 2 (2033 to 2038) will be too late for flying the flag for sustainability.

Comment noted.
Chapter 6.6 of the SPD sets out the range of necessary public transport improvements including the requirement for improved bus services.
Chapter 7.4 of the SPD sets out that infrastructure will be secured at the appropriate time as the development comes forward through the use of planning conditions and legal agreements.
Criterion e of the open space guidelines sets out that the Green Bridge should also provide an ecological function.

Comment

Representation ID: 430

Received: 12/12/2025

Respondent: CPRE Kent

Density
Once this site is development is completed it will appear as an urban extension to Medway, bounded physically by the M2. As such development should take place at a density that is commensurate with urban living, with an appropriate level of open space/landscaping.
The proposed densities do not accord with the guidance set out in the National Design Code. For instance, the highest density across the site is only 40dph – which is “suburban” in character, with medium and lower density areas being even less.
As an urban extension to the Medway Towns development should be significantly increased.

Section 6.7 provides guidance on placemaking, density and character in accordance with policy LPRSP4(b) which also takes into account the sites wider context, including its relationship with the Kent Downs National Landscape which requires to be treated with an appropriate density of 20-25dpa.

Comment

Representation ID: 431

Received: 12/12/2025

Respondent: CPRE Kent

Affordable housing
The adopted Local Plan Review requires 40% affordable housing at Lidsing, yet the SPD avoids committing to this on a phase-by-phase basis. Instead, it suggests that affordable housing should be delivered “across the development”, with the caveat “where possible” for each substantive phase. This approach is wholly inadequate and will not ensure delivery.
Based on long-established experience across Kent, early phases of large strategic sites routinely claim reduced viability owing to upfront infrastructure costs, displacing affordable housing to later phases—if it is delivered at all.
The SPD must require:
• binding Affordable Housing Delivery Plan, agreed prior to the first outline planning permission,
with clearly defined minimum percentages for each phase
• triggers preventing occupation of market units where phase requirements are not met; and a
• mechanism preventing the deferral of affordable housing to later phases.
Anything less risks substantial under-delivery and would undermine one of the core purposes of the allocation, namely the provision of genuinely affordable homes in a strategic location.

Comment noted. Detailed mechanisms regarding affordable housing will be agreed as part of the forthcoming planning applications which will include appropriate legal mechanisms through the S106 agreement.
However officers agree that reference to an Affordable Housing Statement should be included under Criterion B with Appendix B updated accordingly.

Comment

Representation ID: 432

Received: 12/12/2025

Respondent: CPRE Kent

CPRE Kent is the county branch of the countryside charity CPRE, representing more than 1,174 members across Kent and working to protect the beauty, tranquillity and diversity of the county’s rural landscapes. We have been engaged with the Lidsing proposals since their inception in the Council’s recently adopted Local Plan Review.

Background
CPRE Kent remains firmly of the view that Lidsing is the wrong development in the wrong location. While we recognise that the site is now an allocation in the adopted Local Plan, nothing within the draft Supplementary Planning Document (SPD) alters our longstanding conclusions about the harm the proposed development would have in relation to the landscape and infrastructure constraints of the site.
At 2,000 dwellings CPRE Kent is of the view the development at Lidsing should be considered as an urban extension to the Medway towns, rather than a sustainable community in its own right. Although within the Maidstone borough boundary it is likely that future residents will look to Medway to provide for their day-to-day facilities and services, being geographically isolated from Maidstone town.
As stated in our previous comments (in relation to the then draft LPR) our particular concerns related to:
• the need to provide substantial open space and green infrastructure benefits
• the provision of significant structural landscaping mitigation, particularly in the context of the designated National Landscape and its setting – including in relation to the new (elevated) junction works on the M2
• prioritise active travel to achieve an appropriate level of permeability across the site
• provision of a clear understanding of how far residents will need to (active) travel in time (not distance) to find an optician, dentist, GP, hairdresser, beauty salon, childminder, pre-school, post office, bank and enjoy leisure activities – such as gym membership, sports and social clubs, cafés, pubs, restaurants, shops and so on; and whether these activities would need to be curtailed in response to bad weather and dark evenings
• seeking confirmation that bus services will be fast and frequent, and safe during hours of darkness and that bus operators are willing/able to provide enhanced services linking to Lordswood and Hempstead; and Boxley and Bredhurst (and Maidstone, beyond)
• the need for early provision of the local centre to ensure that sustainability of this new community keeps pace with development - as with public transport provision, car habits will already be established on moving into the development (and be difficult to break/change).

Overarching comments
Lidsing is envisaged to come forward within a 12-15 year time period (from 2028 to 2042), extending well beyond the expected lifespan of Maidstone Borough Council itself, which is due to be abolished under forthcoming Local Government Reforms. The SPD must therefore operate as a lasting and authoritative reference point for future decision-makers. However, the consultation draft of the SPD is vague, permissive and insufficiently detailed. In practice, the document appears intentionally flexible, granting maximum latitude to future developers rather than setting clear and enforceable standards. This is the opposite of what is required to secure long-term protection, clarity and accountability.
For example, it is not clear from the draft SPD what is meant by a “flexibly designed bus route network” – see part (h) key principles/guidance - movement & connectivity; and (under the section marked anticipated S.106 agreements) the apparent get-out-clause of providing 40% affordable housing “where possible within each substantive phase of development”.
While we recognise that an SPD cannot introduce new policy, we do consider it essential that the full text of the relevant adopted Local Plan Review policies —specifically LPRSP4(B) —be reproduced within the final SPD for ease of reference. This is not merely a matter of convenience, it is a practical requirement to ensure clarity, transparency and consistency in guiding multiple planning applications over the next two decades.
Without the full policy text, readers must continually cross-consult separate documents. There is a risk that the precise requirements of the adopted Local Plan—particularly those relating to phasing, infrastructure, design quality, landscape protection and affordable housing—are diluted or misunderstood.
Including the adopted policy in full will help ensure that decision-makers, developers and residents are working from the same authoritative baseline which will serve as a continual reminder of what was Examined, found sound, and ultimately adopted as part of the statutory development plan.
Against this context, the SPD must provide a far clearer and more robust design framework than is currently proposed. While we accept that detailed Design Codes will be prepared at later stages, these cannot be created in a vacuum. For a strategic site of this scale and sensitivity, the SPD must itself set out the key design parameters—density envelopes, building height limits, settlement edges, landscape thresholds, neighbourhood structure, and required transitions to the Kent Downs National Landscape—from which all future codes, masterplans and planning applications will flow. For transparency, the path to development should be front-loaded.
At the same time, it is important to recognise that the national planning system is undergoing significant reform: under the Levelling-up and Regeneration Act, SPDs are to be phased out and replaced by statutory “Supplementary Plans” subject to independent examination. This reflects the Government’s clear intention that major developments should be guided by documents carrying full statutory development plan weight, not informal guidance. Given this, and with key infrastructure such as the railway station still so uncertain, there is a strong case for the Council to pause and reflect on whether pressing ahead on the soon to be legacy system is a sensible course of action.
We are concerned that a project of this scale and sensitivity is going to be anchored to a document type that is shortly to be downgraded in status. At the very least, the Council should commit to replacing the SPD with a statutory Supplementary Plan once transitional arrangements are clarified and there is greater certainty regarding the railway station. Without such a commitment, Heathlands risks progressing on the basis of a document that is neither robust nor enforceable, leaving future decision-makers—and the public—facing uncertainty that should have been resolved from the outset.

Comment noted.
The Framework Plans set out at Chapter 5 of the SPD capture the key structuring elements and principles, whilst also allowing for appropriate flexibility for further design work to consider matters in more detail and bring forward appropriate proposals.
Future planning applications will set out more details around the proposed layout of buildings, uses and infrastructure across the site. All future applications will be the subject of consultation and future decision making.
The SPD sets out guidance and principles across a number of key themes and topics, especially within 'Section C: Placemaking & Design Guidelines'. Each theme has a clear section which sets out 'Key Principles/Guidance' specific to each theme.
Future planning applications will have to consider and demonstrate how they have addressed all stated requirements.